Ohio Admin. Code 3745-21-25
[Comment: For dates and availability of non-regulatory government publications, publications of recognized organizations and associations, federal rules, and federal statutory provisions referenced in this rule, see paragraph (JJ) of rule 3745-21-01 of the Administrative Code titled "referenced materials."]
The definitions applicable to this rule are contained in paragraphs (A), (B) and (GG) of rule 3745-21-01 of the Administrative Code.
[Note: The exclusion of certain operations from this rule applies only to operations specifically listed in this paragraph. This rule still applies to any colocated operations. For example, although polymer casting and resin transfer molding operations are specifically excluded from this rule, any gel coating, mixing, VOC-containing materials storage, or cleaning operation associated with a polymer casting operation or a resin transfer molding operation is still subject to this rule.]
The provisions of paragraphs (D)(1) to (D)(10) of this rule shall not apply to any emissions unit that meets the following:
Calculate a weighted average VOC emissions factor on a pounds per ton of resin, monomer, or gel coat basis. Base the weighted average on the prior twelve months of operation. Multiply the weighted average VOC emissions factor by resin, monomer, or gel coat use over the same period. The owner or operator may calculate this VOC emissions factor based on the equations in table 1 of 40 CFR part 63, subpart WWWW, or the owner or operator may use any VOC emissions factor approved by USEPA, such as emission factors or emission factor equations from AP-42, or site-specific VOC emissions factors if they are supported by VOC emissions test data. The organic HAP emissions factors in table 1 of 40 CFR part 63, subpart WWWW are equivalent to the VOC emissions factors for this rule.
Conduct performance testing using the test procedures in 40 CFR 63.5850 or paragraph (C) of rule 3745-21-10 of the Administrative Code to determine a site-specific VOC emissions factor in units of pounds of VOC per ton of resin, monomer, or gel coat used. Conduct the test under conditions expected to result in the highest possible VOC emissions. Multiply this factor by annual resin, monomer, or gel coat use to determine annual VOC emissions. This calculation shall be repeated and reported annually.
For pultrusion operations employing enclosures or resin injection (direct or preform) pursuant to paragraph (I)(5)(b) of this rule, actual emissions may be calculated as four tenths and one tenth, respectively, of open line emissions, where open line emissions are calculated as specified in air permits covering these operations.
The owner or operator shall use one of the following methods in paragraphs (G)(1) to (G)(4) of this rule to meet the VOC emissions limits for open molding or centrifugal casting operations specified in table 2 or table 3 of this rule. The owner or operator may use any control method that reduces VOC emissions, including reducing resin and gel coat monomer content, changing to nonatomized mechanical application, using covered curing techniques, and routing part or all of the VOC emissions to an add-on control. The owner or operator may use different compliance options for the different operations listed in table 2 or table 3 of this rule. The necessary calculations shall be completed within thirty days after the end of each month. The owner or operator may switch between the compliance options in paragraphs (G)(1) to (G)(4) of this rule. When the owner or operator changes to an option based on a twelvemonth rolling average, the owner or operator shall base the average on the previous twelve months of data calculated using the compliance option the owner or operator is changing to, unless the owner or operator was previously using an option that did not require the owner or operator to maintain records of resin and gel coat use. In this case, the owner or operator shall immediately begin collecting resin and gel coat use data and demonstrate compliance twelve months after changing options.
Add-on Control Factor = 1 - (% Control Efficiency / 100)
where:
Per cent control efficiency = value calculated from VOC emissions test measurements made according to 40 CFR 63.5850.
where:
Actual Process Stream EFi = actual VOC emissions factor for process stream i, pounds of VOC per ton of neat resin plus or neat gel coat plus.
Materiali = the amount of neat resin plus or neat gel coat plus used during the last twelve calendar months for process stream i, tons.
n = number of process streams where the owner or operator calculated a VOC emissions factor.
Demonstrate each month that each weighted average of the VOC emissions limits in table 2 or table 3 of this rule that apply are being met. When using this option, the owner or operator shall demonstrate compliance with the weighted average VOC emissions limit for all open molding operations, and then separately demonstrate compliance with the weighted average VOC emissions limit for all centrifugal casting operations. Open molding operations and centrifugal casting operations may not be averaged with each other.
where:
ELi= VOC emissions limit for operation type i, pounds per ton from table 2 or table 3 of this rule.
Materiali = amount of neat resin plus or neat gel coat plus used during the last twelve-month period for operation type i, tons.
n = number of operations.
where:
Actual Operation EFi = Actual VOC emissions factor for operation type i, pounds of VOC per ton of neat resin plus or neat gel coat plus.
Materiali = amount of neat resin plus or neat gel coat plus used during the last twelve calendar months for operation type i, tons.
n = number of operations.
This option is limited to resins of the same type. The resin types for which this option may be used are noncorrosion-resistant, corrosion-resistant or high strength, and tooling.
For continuous casting/lamination operations, the owner or operator shall use one or more of the options listed in paragraphs (H)(1) to (H)(4) of this rule to meet the VOC emissions limits specified in table 2 or table 3 of this rule and shall use the calculation procedures provided in paragraphs (J) to (M) of this rule.
Demonstrate that each continuous lamination line and each continuous casting line complies with the applicable VOC emissions limit.
Demonstrate that all continuous lamination and continuous casting lines combined, comply with the applicable VOC emissions limit.
If the operation shall meet the 58.5 weight per cent VOC emissions reduction limit in table 2 of this rule, the owner or operator has the option of demonstrating that the operation achieves ninety-five per cent reduction of all wet-out area VOC emissions.
Use any combination of options in paragraphs (H)(1) to (H)(3) of this rule.
For pultrusion operations, the owner or operator shall use one or more of the options in paragraphs (I)(1) to (I)(5) of this rule to meet the sixty weight per cent VOC emissions limit in table 2 of this rule.
To calculate the annual uncontrolled and controlled VOC emissions from the wet-out areas and from the ovens of continuous lamination/casting operations, the owner or operator shall develop uncontrolled and controlled wet-out area and uncontrolled and controlled oven VOC emissions estimation equations or factors to apply to each formula applied on each line, determine how much of each formula for each end product is applied each year on each line, and assign uncontrolled and controlled wet-out area and uncontrolled and controlled oven VOC emissions estimation equations or factors to each formula. The owner or operator shall determine the overall capture efficiency using the procedures in 40 CFR 63.5850.
Use the following procedures to determine how much neat resin plus and neat gel coat plus is applied to the line each year:
The owner or operator shall calculate per cent reduction for continuous lamination/ casting operations using any of the following methods:
If all of the wet-out areas have a PTE that meets USEPA method 204 of 40 CFR part 51, appendix M, and all of the wet-out area VOC emissions and oven VOC emissions are vented to an add-on control device, use the equation in paragraph (M)(1)(a) of this rule to demonstrate compliance. In all other situations, use the equation in paragraph (M)(1)(b) of this rule to demonstrate compliance.
PR = ((Inlet - Outlet) / Inlet) x 100
where:
PR = per cent reduction.
Inlet = VOC emissions entering the control device, pounds of VOC per year.
Outlet = VOC emissions exiting the control device to the atmosphere, pounds of VOC per year.
PR = (((WAEci + Oci) - (WAEco + Oco)) / (WAEci + WAEu + Oci + Ou)) x 100
where:
PR = per cent reduction.
Oci = oven VOC emissions, pounds of VOC per year, vented to a control device.
Oco = oven VOC emissions, pounds of VOC per year, from the control device outlet.
Ou = oven VOC emissions, pounds of VOC per year, not vented to a control device.
WAEci = wet-out area VOC emissions, pounds of VOC per year, vented to a control device.
WAEco = wet-out area VOC emissions, pounds of VOC per year, from the control device outlet.
WAEu = wet-out area VOC emissions, pounds of VOC per year, not vented to a control device.
Use the following equation to calculate per cent reduction:
where:
PR = per cent reduction.
Ojci = VOC emissions from oven j, pounds of VOC per year, sent to a control device.
Ojco = VOC emissions from oven j, pounds of VOC per year, at the outlet of the control device.
Oju = VOC emissions from oven j, pounds of VOC per year, not sent to a control device.
WAEici = wet-out area VOC emissions from wet-out area i, pounds of VOC per year, sent to a control device.
WAEico = wet-out area VOC emissions from wet-out area i, pounds of VOC per year, at the outlet of a control device.
WAEiu = wet-out area VOC emissions from wet-out area i, pounds of VOC per year, not sent to a control device.
m = number of wet-out areas.
n = number of ovens.
Use the equation in paragraph (M)(1)(a) of this rule to calculate per cent reduction.
Use the equations in paragraphs (M)(1)(a), (M)(1)(b), and (M)(2) of this rule, as applicable, to calculate per cent reduction.
Use the following equation to calculate a VOC emissions factor in pounds of VOC per ton of neat resin plus and neat gel coat plus.
E = (WAEu + WAEc + Ou + Oc) / (R + G)
where:
E = VOC emissions factor in pounds of VOC per ton of neat resin plus and neat gel coat plus.
WAEu = uncontrolled wet-out area VOC emissions, pounds of VOC per year.
WAEc = controlled wet-out area VOC emissions, pounds of VOC per year.
Ou = uncontrolled oven VOC emissions, pounds of VOC per year.
Oc = controlled oven VOC emissions, pounds of VOC per year.
R = total usage of neat resin plus, tons per year.
G = total usage of neat gel coat plus, tons per year.
Use the following equation to demonstrate compliance:
where:
E = VOC emissions factor in pounds of VOC per ton of resin and gel coat.
WAEui = uncontrolled VOC emissions from wet-out area i, pounds of VOC per year.
WAEci = controlled VOC emissions from wet-out area i, pounds of VOC per year.
Ouj = uncontrolled VOC emissions from oven j, pounds of VOC per year.
Ocj = controlled VOC emissions from oven j, pounds of VOC per year.
i = number of wet-out areas.
j = number of ovens.
m = number of wet-out areas uncontrolled.
n = number of ovens uncontrolled.
o = number of wet-out areas controlled.
p = number of ovens controlled.
R = total usage of neat resin plus, tons per year.
G = total usage of neat gel coat plus, tons per year.
Use the equations in paragraphs (N)(1) and (N)(2) of this rule, as applicable, to demonstrate compliance.
Table 1: Work practice standards. As required in paragraph (D)(1) of this rule, the owner or operator shall meet the work practice standards specified by type of operation in the following table:
Type of operation | Work practice standards |
1. Compression/injection molding | Uncover, unwrap or expose only one charge per mold cycle per compression/injection molding machine. For machines with multiple molds, one charge means sufficient material to fill all molds for one cycle. For machines with robotic loaders, no more than one charge may be exposed prior to the loader. For machines fed by hoppers, sufficient material may be uncovered to fill the hopper. Hoppers shall be closed when not adding materials. Materials may be uncovered to feed to slitting machines. Materials shall be recovered after slitting. |
2. Cleaning operation (cleaning of equipment used in reinforced plastic composites manufacture) | Do not use cleaning solvents (cleaners) that have a VOC content greater than 0.42 pound VOC per gallon, except cleaners used in closed systems and used to clean cured resin from application equipment. Application equipment includes any equipment that directly contacts resin. |
3. VOC-containing materials storage operation | Keep containers that store VOC-containing materials closed or covered except during the addition or removal of materials. Bulk VOC-containing materials storage tanks may be vented as necessary for safety. |
4. SMC manufacturing operation | a. Close or cover the resin delivery system to the doctor box on each SMC manufacturing machine. The doctor box itself may be open. |
b. Use a nylon containing film to enclose SMC. | |
5. All mixing or BMC manufacturing operations1 | a. Use mixer covers with no visible gaps present in the mixer covers, except that gaps of up to 1.0 inch are permissible around mixer shafts and any required instrumentation. |
b. Close any mixer vents when actual mixing is occurring, except that venting is allowed during addition of materials, or as necessary prior to adding materials or opening the cover for safety. Vents routed to a ninety-five per cent efficient control device are exempt from this requirement. | |
c. Keep the mixer covers closed while actual mixing is occurring except when adding materials or changing covers to the mixing vessels. | |
6. Pultrusion operation manufacturing parts that meet the following criteria: one thousand or more reinforcements or the glass equivalent of one thousand ends of one hundred thirteen yield roving or more; and have a cross-sectional area of sixty square inches or more that is not subject to the ninety-five per cent VOC emissions reduction requirement | a. Do not allow vents from the building ventilation system, or local or portable fans to blow directly on or across the wet-out area. |
b. Do not permit point suction of ambient air in the wet-out area unless that air is directed to a control device. | |
c. Use devices such as deflectors, baffles, and curtains when practical to reduce air flow velocity across the wet-out area. | |
d. Direct any compressed air exhausts away from resin and wet-out area. | |
e. Convey resin collected from drip-off pans or other devices to reservoirs, tanks, or sumps via covered troughs, pipes, or other covered conveyance that shields the resin from the ambient air. | |
f. Cover all reservoirs, tanks, sumps, or VOC-containing materials storage vessels except when they are being charged or filled. | |
g. Cover or shield from ambient air resin delivery systems to the wet-out area from reservoirs, tanks, or sumps where practical. |
1Containers of five gallons or less may be open when active mixing is taking place, or during periods when they are in process (i.e., they are actively being used to apply resin). For polymer casting mixing operations, containers with a surface area of five hundred square inches or less may be open while active mixing is taking place.
Table 2: VOC Emissions limits for specific open molding, centrifugal casting, pultrusion and continuous lamination/casting operations at facilities with VOC emissions less than the threshold of one hundred tons of VOC per year. As required in paragraph (D)(2) of this rule, the owner or operator shall meet the VOC emissions limits specified by type of operation and resin application method or gel coat type in the following table:
Type of operation | Resin application method or gel coat type | VOC emissions limit1 |
1. Open molding: corrosion-resistant and/or high strength (CR/ HS) | a. Mechanical resin application | 113 lb/ton |
b. Filament application | 171 lb/ton | |
c. Manual resin application | 123 lb/ton | |
2. Open molding: non-CR/HS | a. Mechanical resin application | 88 lb/ton |
b. Filament application | 188 lb/ton | |
c. Manual resin application | 87 lb/ton | |
3. Open molding: tooling | a. Mechanical resin application | 254 lb/ton |
b. Manual resin application | 157 lb/ton | |
4. Open molding: low-flame spread/low-smoke products | a. Mechanical resin application | 497 lb/ton |
b. Filament application | 270 lb/ton | |
c. Manual resin application | 238 lb/ton | |
5. Open molding: shrinkage controlled resins2 | a. Mechanical resin application | 354 lb/ton |
b. Filament application | 215 lb/ton | |
c. Manual resin application | 180 lb/ton | |
6. Open molding: gel coat3 | a. Tooling gel coat | 440 lb/ton |
b. White/off white pigmented gel coat | 267 lb/ton | |
c. All other pigmented gel coat | 377 lb/ton | |
d. CR/HS or high performance gel coat | 605 lb/ton | |
e. Fire retardant gel coat | 854 lb/ton | |
f. Clear production gel coat | 522 lb/ton | |
7. Centrifugal casting: CR/HS | a. Resin application with the mold closed, and the mold is vented during spinning and cure | 25 lb/ton4 |
b. Resin application with the mold closed, and the mold is not vented during spinning and cure | Not applicable (this is considered to be a closed molding operation) | |
c. Resin application with the mold open, and the mold is vented during spinning and cure | 25 lb/ton4 | |
d. Resin application with the mold open, and the mold is not vented during spinning and cure | Use the appropriate open molding emission limit5 | |
8. Centrifugal casting: non-CR/HS | a. Resin application with the mold closed, and the mold is vented during spinning and cure | 20 lb/ton4 |
b. Resin application with the mold closed, and mold is not vented during the spinning and cure | Not applicable (this is considered to be a closed molding operation) | |
c. Resin application with the mold open, and the mold is vented during spinning and cure | 20 lb/ton4 | |
d. Resin application with the mold open, and the mold is not vented during spinning and cure | Use the appropriate open molding emission 5 limit5 | |
9. Pultrusion6 | Not applicable | Reduce total VOC emissions by at least sixty per cent by weight |
10. Continuous lamination/casting | Not applicable | Reduce total VOC emissions by at least 58.5 per cent by weight or not exceed a VOC emissions limit of 15.7 pounds of VOC per ton of neat resin plus and neat gel coat plus |
1VOC emissions limits for open molding and centrifugal casting are expressed as pounds of VOC per ton of resin or gel coat (pounds per ton). The operation shall be at or below these values based on a twelve-month rolling average.
2This emission limit applies regardless of whether the shrinkage controlled resin is used as a production resin or a tooling resin.
3If applying gel coat with manual application, for compliance purposes treat the gel coat as if it were applied using atomized spray guns to determine both emission limits and emission factors. If using multiple application methods and any portion of a specific gel coat is applied using nonatomized spray, the owner or operator may use the nonatomized spray gel coat equation to calculate an emission factor for the manually applied portion of that gel coat. Otherwise, use the atomized spray gel coat application equation to calculate emission factors.
4For compliance purposes, calculate the VOC emission factor using only the appropriate centrifugal casting equation in item 2 of table 1 of 40 CFR part 63, subpart WWWW, or a site-specific emission factor for after the mold is closed as discussed in paragraph (E) (1) of this rule.
5Calculate the emission factor using the appropriate open molding covered cure emission factor in item 1 of table 1 of 40 CFR part 63, subpart WWWW, or a site-specific emission factor as discussed in paragraph (E)(1) of this rule.
6Pultrusion machines that produce parts that meet the following criteria: one thousand or more reinforcements or the glass equivalent of one thousand ends of one hundred thirteen yield roving or more; and have a cross sectional area of sixty square inches or more are not subject to this requirement. the requirement is the work practice of air flow management which is described in table 1 of this rule.
Table 3: Alternative VOC emissions limits for open molding, centrifugal casting, and continuous lamination/casting operations at facilities with VOC emissions equal to or greater than the threshold of one hundred tons of VOC per year. As provided in paragraph (D)(3) of this rule, as an alternative to the ninety-five per cent VOC emissions reductions requirement, the owner or operator may meet the appropriate VOC emissions limits specified by type of operation and resin application method, gel coat type, or vent system type in the following table:
Type of operation | Resin application method | VOC emissions limit1 |
1. Open molding: corrosion-resistant and/or high strength (CR/HS) | a. Mechanical resin application | 6 lb/ton |
b. Filament application | 9 lb/ton | |
c. Manual resin application | 7 lb/ton | |
2. Open molding: non-CR/ HS | a. Mechanical resin application | 13 lb/ton |
b. Filament application | 10 lb/ton | |
c. Manual resin application | 5 lb/ton | |
3. Open molding: tooling | a. Mechanical resin application | 13 lb/ton |
b. Manual resin application | 8 lb/ton | |
4. Open molding: low flame spread/low smoke products | a. Mechanical resin application | 25 lb/ton |
b. Filament application | 14 lb/ton | |
c. Manual resin application | 12 lb/ton | |
5. Open molding: shrinkage controlled resins | a. Mechanical resin application | 18 lb/ton |
b. Filament application | 11 lb/ton | |
c. Manual resin application | 9 lb/ton | |
6. Open molding: gel coat: Open molding: gel coat2 | a. Tooling gel coat | 22 lb/ton |
b. White/off white pigmented gel coat | 22 lb/ton | |
c. All other pigmented gel coat | 19 lb/ton | |
d. CR/HS or high performance gel coat | 31 lb/ton | |
e. Fire retardant gel coat | 43 lb/ton | |
f. Clear production gel coat | 27 lb/ton | |
7. Centrifugal casting: CR/ HS3,4 | a. Uses a vent system that moves heated air through the mold | 27 lb/ton |
b. Uses a vent system that moves ambient air through the mold | 2 lb/ton | |
8. Centrifugal casting: non-CR/HS3,4 | a. Uses a vent system that moves heated air through the mold | 21 lb/ton |
b. Uses a vent system that moves ambient air through the mold | 1 lb/ton | |
9. Continuous lamination/ casting | Not applicable | 1.47 lb/ton |
1For open molding and centrifugal casting operations, the VOC emissions limits are expressed as pounds of VOC per ton of resin or gel coat used (pound per ton). For a continuous lamination/casting operation, the VOC emissions limit is expressed as pounds of VOC per ton of neat resin plus and neat gel coat plus used. The operations shall be at or below these values based on a twelve-month rolling average.
2These limits are for spray application of gel coat. Manual gel coat application shall be included as part of spray gel coat application for compliance purposes using the same VOC emissions factor equation and VOC emissions limit. If only gel coat is applied with manual application, treat the manually applied gel coat as if it were applied with atomized spray for compliance determinations.
3Centrifugal casting operations where the mold is not vented during spinning and cure are considered to be closed molding and are not subject to any emissions limit. Centrifugal casting operations where the mold is not vented during spinning and cure, and the resin is applied to the open centrifugal casting mold using mechanical or manual open molding resin application techniques are considered to be open molding operations and the appropriate open molding emission limits apply.
4Centrifugal casting operations where the mold is vented during spinning and the resin is applied to the open centrifugal casting mold using mechanical or manual open molding resin application techniques, are to use the appropriate centrifugal casting emission limit to determine compliance. Calculate the emission factor using the appropriate centrifugal casting emission factor in table 1 of 40 CFR part 63, subpart WWWW, or a site-specific emissions factor as discussed in paragraph (E)(1) of this rule.
Table 4: Options allowing use of the same resin across different operations that use the same resin type. As provided in paragraph (G)(4) of this rule, when electing to use the same resin for multiple resin application methods, the owner or operator may use any resin with a monomer content less than or equal to the values shown in the following table, or any combination of resins whose weighted average monomer content based on a twelve-month rolling average is less than or equal to the values shown in the following table:
Type of operation | Resin application method | Monomer content limit (per cent by weight of resin) |
1. CR/HS resins, centrifugal casting1,2 | a. CR/HS mechanical3 | 48.0 |
b. CR/HS filament application | 48.0 | |
c. CR/HS manual | 48.0 | |
2. CR/HS resins, nonatomized mechanical | a. CR/HS filament application | 46.4 |
b. CR/HS manual | 46.4 | |
3. CR/HS resins, filament application | CR/HS manual | 42.0 |
4. Non-CR/HS resins, filament application | a. Non-CR/HS mechanical3 | 45.0 |
b. Non-CR/HS manual | 45.0 | |
c. Non-CR/HS centrifugal casting1,2 | 45.0 | |
5. Non-CR/HS resins, nonatomized mechanical | a. Non-CR/HS manual | 38.5 |
b. Non-CR/HS centrifugal casting1,2 | 38.5 | |
6. Non-CR/HS resins, centrifugal casting1,2 | Non-CR/HS manual | 37.5 |
7. Tooling resins, nonatomized mechanical | Tooling manual | 91.4 |
8. Tooling resins, manual | Tooling atomized mechanical | 45.9 |
1If the centrifugal casting operation blows heated air through the molds, then ninety-five per cent capture and control shall be used if the owner or operator wishes to use this compliance option.
2If the centrifugal casting molds are not vented, the owner or operator may treat the centrifugal casting operations as if the molds were vented if the owner or operator wishes to use this compliance option.
3Nonatomized mechanical application shall be used.
Ohio Admin. Code 3745-21-25
Five Year Review (FYR) Dates: 11/29/2021 and 11/29/2026
Promulgated Under: 119.03
Statutory Authority: 3704.03(E)
Rule Amplifies: 3704.03(A), 3704.03(E)
Prior Effective Dates: 12/14/2009, 11/11/2010, 10/15/2015, 02/16/2019